San Mateo County Regional Assessment of Fair Housing San Mateo County and Participating Partners DRAFT REPORT Draft Report August 1, 2017 San Mateo Regional Assessment of Fair Housing Prepared for San Mateo County and Participating Partners Prepared by BBC Research & Consulting 1999 Broadway, Suite 2200 Denver, Colorado 80202‐9750 303.321.2547 fax 303.399.0448 www.bbcresearch.com [email protected] Table of Contents I. Cover Sheet II. Executive Summary What is an AFH? ........................................................................................................................ II–1 Fair Housing Law and Enforcement ........................................................................................... II–2 Community Participation Process ............................................................................................. II–3 Summary of AFH Findings ......................................................................................................... II–5 Contributing Factors to Primary Fair Housing Issues ................................................................ II–6 Goals and Strategies ................................................................................................................ II–11 III. Community Participation Process Outreach Activities ................................................................................................................... III–1 Stakeholder Consultation Summary ......................................................................................... III–5 Resident Public Participation Summary ................................................................................... III–6 Public Hearings and Public Comment Period ........................................................................... III–8 IV. Assessment of Past Goals, Actions and Strategies 2012 Impediments, Actions and Accomplishments ................................................................ IV–1 Additional Efforts and Selection of Current Goals .................................................................. IV–5 V. Fair Housing Analysis Demographic Summary ............................................................................................................ V–2 General Issues ........................................................................................................................ V–15 Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) .......................................... V–39 Disparities in Access to Opportunity ...................................................................................... V–41 Disproportionate Housing Needs ........................................................................................... V–73 Publicly Supported Housing Analysis .................................................................................... V–113 Disability and Access Analysis .............................................................................................. V–124 Fair Housing Enforcement, Outreach Capacity, and Resources Analysis ............................. V–139 VI. Fair Housing Goals and Priorities Goals Development ................................................................................................................. VI–2 Appendices A. Community Engagement B. Comments and Communications C. Community Outreach Materials D. Guide to HUD Access to Opportunity Indicators BBC RESEARCH & CONSULTING i SECTION I. Cover Sheet SECTION II. Executive Summary SECTION II. EXECUTIVE SUMMARY This section summarizes the main findings from the San Mateo County Regional Assessment of Fair Housing (AFH). Pursuant to HUD’s requirements, this Executive Summary: Summarizes the primary fair housing issues, significant contributing factors, and goals, and Provides an overview of the process and analysis used to reach goals. It begins with a brief background on the AFH and continues to an overview of the process. What is an AFH? An Assessment of Fair Housing, or AFH, is a new approach to identifying fair housing challenges in a city and region. This document differs from the formerly required Analysis of Impediments to Fair Housing Choice (AI) in that embraces a more comprehensive planning process, focusing on economic, as well as housing, barriers. The AFH is required by the U.S. Department of Housing and Urban Development (HUD) of communities that accept federal housing and community development funding.1 The overall goal of the AFH approach is to help communities analyze challenges to fair housing choice and establish their own goals and priorities to address fair housing barriers in their communities. A secondary goal is to help communities move toward an “access to opportunity philosophy” when making planning and housing policy decisions. The “access to opportunity” focus of the AFH is rooted in the text of the 1968 Fair Housing Act (FHA). According to the July 2015 Final Rule establishing the AFH, “The Fair Housing Act not only prohibits discrimination, but, in conjunction with other statutes, directs HUD’s program participants to take significant actions to overcome historical patterns of segregation, achieve truly balanced and integrated living patterns, promote fair housing choice, and foster inclusive communities that are free from discrimination.” 2 Many court decisions have supported this interpretation of the FHA. Jurisdiction v. region terminology. The “jurisdiction” as defined by the AFH is the city or county or groups of cities and counties that receive HUD block grant funds directly from HUD. The cities participating in this AFH are Daly City, Redwood City, the City of San Mateo, and South 11 It is important to note that a jurisdiction can be found in violation of the Federal Fair Housing Act independent of receiving HUD funding. While the obligation to further fair housing is a condition of receiving federal housing and community development funds, all other provisions in the Fair Housing Act apply to all residents, businesses, and state and local governments. 2 https://www.huduser.gov/portal/affht_pt.html#final‐rule. BBC RESEARCH & CONSULTING SECTION II, PAGE 1 San Francisco. The lead entity is San Mateo County. The Housing Authority of San Mateo County is also a participating partner, along with the Housing Authority of South San Francisco. For the purposes of the AFH, the “region” used in comparative analysis is the Core Based Statistical Area, or CBSA. CBSA boundaries are set by the U.S. Office of Management and Budget (OMB) and include both metropolitan and micropolitan (smaller consolidated cities) areas. In addition to San Mateo County, the San Francisco CBSA includes Alameda County, Contra Costa County, San Francisco County, and Marin County. San Mateo County makes up about 17 percent of the region’s population. Consistent with the terminology used in the AFFH maps, the CBSA will be referred to as the “region” in this document. Fair Housing Law and Enforcement The Fair Housing Act (FHA) was part of the federal Civil Rights Act of 1968. The original language in the FHA prohibited discrimination in the sale, rental and financing of dwellings in housing‐related transactions based on race, color, national origin and religion. The FHA was amended twenty years later, in 1988, to prohibit discrimination on the basis of disability or familial status, and to require accessible units in multifamily developments built after 1991. Developments exempted from the FHA include: housing developments for seniors, housing strictly reserved for members of religious organizations or private clubs, and multifamily housing of four units or less with the owner occupying one unit. San Mateo County residents are fortunate to have a number of local organizations active in fair housing law. These include Project Sentinel, Legal Aid of San Mateo County, and Community Legal Services. The San Francisco Fair Housing and Equal Opportunity (FHEO) office of HUD and the State of California Department of Fair Employment and Housing also investigate fair housing violations. Contact information for each of these organizations is shown below. Figure II‐1. Local Resources for Fair Housing Information and Complaints Name URL Phone Number 888‐FAIR‐HOUSING Project Sentinel www.housing.org (888‐324‐7468) Legal Aid Society of San Mateo http://www.legalaidsmc.org/housing‐ 650‐558‐0915 County resources.html Community Legal Services of East http://clsepa.org/ 650‐326‐6440 Palo Alto California Department of Fair www.dfeh.ca.gov Employment and Housing Federal Department of Housing https://portal.hud.gov/hudportal/HUD?src= and Urban Development /program_offices/fair_housing_equal_opp BBC RESEARCH & CONSULTING SECTION II, PAGE 2 Community Participation Process The San Mateo County Regional AFH’s community participation process resulted in meaningful engagement of more than 4,000 residents and stakeholders representing local organizations and coalitions. Methods of engagement. The regional AFH engagement methods included opportunities for residents and opportunities for stakeholders to participate in the development of the AFH. Resident opportunities included: Resident survey. The resident survey was available in online and postage‐paid printed formats. Residents could take the survey in English, Spanish, Chinese and Tagalog. Resident focus groups. BBC facilitated four resident focus groups—one in Spanish; one with Filipino residents; a group with Section 8 voucher holders, including Moving to Work participants; and a focus group with